Schedule Y

What Is Schedule Y
• It is “Schedule under Part X-A of Drugs & Cosmetics
Rule 1945 describe the information/data required –
Requirements and guidelines for permission to
import and/or manufacture of new drugs for
sale or undertake clinical trials

Salient Features of Schedule Y
• Provides statutory support to Indian GCP guidelines.
• Stipulates responsibilities of EC, Investigators and Sponsor.
• Structure, contents and formats for CT protocols, reports, EC
approvals, ICF, SAE reporting are incorporated .

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Schedule-Y Amendments - Long Overdue
• The amendment has brought in several good
changes - EC/CRO registration, GCP Compliance
and other related quality changes.
• Safeguard the safety of trial participants and to
improve the following much criticized inefficiencies:
– Misconduct, fraudulent cases of several clinical research
players including CROs, investigators, ECs, regulators and
sponsors.
– Ethical lapses in informed consent issues, protocol
violations, compensation issues among others.

• Compensation has to be paid irrespective of
whether or not the SAE is causally linked to IP.
• If this compensation is not provided, this may lead
to the company suspending/losing the license to
conduct CT in India on a case-by case basis. This is
acting as a deterrent for many pharma MNCs.
• DTAB meeting on May 16th, 2013- causality issue/
if the standard care is denied in case of placebo
trials/ failure of IP to act /streamline the timelines
– these recommendations are highly required to
be enacted

CONCLUSION
• These amendments have brought sudden change to
the CT regulations.
• Many of these amendments were long overdue and
were very much required however without too
many lacunas.
• These changes should have been done in
consultation with the stakeholders (Public,
Sponsors, CROs, Academia, Ethics Committees,
Regulators and Ministry) to avoid the anguish that
the CT industry is undergoing currently.